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Regulator commentary, weekly briefings and country/sanctions analysis from FIRMCY · RSS
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14 October 2026 · Country risk

Brazil AML

Most Brazil country-risk notes I see are a single line. That's the gap: there are four answers, and they don't move together. FATF's call-for-action list…

13 October 2026 · Practice notes

The finding comes first

Simplified due diligence in Cyprus law is a permission, and its condition comes first. A firm may lighten the measures provided it has already satisfied…

13 October 2026 · Practice notes

Up to date is not annual

Cyprus law sets no timetable for a firm's own money laundering risk assessment. It says the assessment is kept up to date. "Annually" is ICPAC's word, and…

13 October 2026 · Sanctions movements

942 list changes in 27 days

The last 27 days on the sanctions lists, 15 September – 12 October 2026: 942 changes — 251 additions, 151 removals and 540 amendments across the EU, OFAC…

11 October 2026 · Sanctions movements

130 removals, zero all-clears

130 names came off the sanctions lists in the week of 5–9 October 2026. 80 of them came off under programme US-SDNT. A removal is not an all-clear. The…

10 October 2026 · Sanctions movements

The week dissected: 422 changes

The week dissected, 5–9 October 2026: 93 additions, 130 removals and 199 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 280…

9 October 2026 · Regulator commentary

185 failed submissions

Cyprus's financial intelligence unit, MOKAS, says a suspicious transaction report fails submission if its narrative is not more than 400 and less than…

9 October 2026 · Regulator commentary

Old files, earlier clock

Customers you already have are not grandfathered. AMLA's final draft EU standard on customer due diligence says their files must be brought in line within…

8 October 2026 · Practice notes

A doubt reopens the file

Most firms go back to a client's due diligence when something new happens: a new deal, a new owner, a bigger sum. Cyprus law also sends them back when…

8 October 2026 · Practice notes

Senior does not mean board

Cyprus law requires the compliance officer to be senior. It does not require a board seat. Senior, as the Law defines it, means knowing enough about the…

8 October 2026 · Change log

1 UK removed

1 removed, 52 amended on the sanctions lists on 8 October 2026. The bulk landed in programme GB-AQD (10 entries). Top country by count: Afghanistan (8…

7 October 2026 · Country risk

Albania AML

Albania files rarely fail on the FATF question. They fail on the date. Four lists decide the answer — FATF's call-for-action and increased-monitoring…

6 October 2026 · Practice notes

Suspicion has no threshold

A one-off job under €15,000 is not, by that fact alone, outside due diligence. In Cyprus law €15,000 is one of several amounts, each tied to a particular…

6 October 2026 · Practice notes

Remote is half the factor

A client you never meet in person is not, by that fact alone, a higher-risk factor under Cyprus law. The factor is a remote relationship or transaction…

6 October 2026 · Sanctions movements

690 list changes in 27 days

The last 27 days on the sanctions lists, 8 September – 5 October 2026: 690 changes — 218 additions, 20 removals and 452 amendments across the EU, OFAC, UK…

4 October 2026 · Sanctions movements

4 removals, zero all-clears

4 names came off the sanctions lists in the week of 28 September – 2 October 2026. 1 of them came off under Libya sanctions (UN-SC1970). A removal is not…

3 October 2026 · Sanctions movements

The week dissected: 336 changes

The week dissected, 28 September – 2 October 2026: 134 additions, 4 removals and 198 amendments across the EU, OFAC, UK and UN lists. Who the entries…

2 October 2026 · Change log

62 added

62 added, 53 amended on the sanctions lists on 2 October 2026. The bulk landed in programme US-IRAN-EO13902 (22 entries). Top country by count: Russia (16…

1 October 2026 · Change log

18 OFAC added

18 added, 3 removed on the sanctions lists on 1 October 2026. The bulk landed in programme US-SDGT, US-TCO (18 entries). Top country by count: Venezuela…

30 September 2026 · Country risk

China AML

Most China files don't get the country-risk answer wrong. They get it once, and never revisit the date. Four separate lists decide it — FATF's…

29 September 2026 · Sanctions movements

308 list changes in 27 days

The last 27 days on the sanctions lists, 1–28 September 2026: 308 changes — 87 additions, 16 removals and 205 amendments across the EU, OFAC, UK and UN…

27 September 2026 · Sanctions movements

3 removals, zero all-clears

3 names came off the sanctions lists in the week of 21–25 September 2026. 2 of them came off under programme US-DRCONGO. A removal is not an all-clear…

26 September 2026 · Sanctions movements

The week dissected: 88 changes

The week dissected, 21–25 September 2026: 0 additions, 3 removals and 85 amendments across the EU, OFAC, UK and UN lists. Who the entries concern: 85…

25 September 2026 · Regulator commentary

Third party, or part of you

The Cyprus Bar Association's new guidelines on third-party reliance turn on the arrangement you have with the person doing the client work. One kind makes…

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Not legal advice. FIRMCY publishes this analysis for general informational purposes; verify against the primary sources before acting.